S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Net margin method-Identical with earlier years-No substantial question of law. [S.260A]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Net margin method-Identical with earlier years-No substantial question of law. [S.260A]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparables-Exclusion of companies large and with functional and segmental dissimilarities-Appreciation of facts-No substantial question of law.[S.92CA(3), 260A]
S. 68 : Cash credits-Share capital-Ready to submit relevant documents-Matter remanded to Assessing Officer for fresh consideration. [S. 260A]
S. 68 : Cash credits-Proved genuineness of transactions-Order of Tribunal deleting the addition is affirmed. [S. 260A]
S. 50B : Capital gains-Slump sale-Sale of business as running concern —Sale is not of itemised assets-Transfer of goodwill and know-how did not give rise to capital gains as no cost of acquisition ascertainable-Not liable to tax. [S. 2(42C), 41(2), 45, 50(2), 50B(2) 55(2)(a), 260A]
S. 50B : Capital gains-Slump sale-Sale of business as running concern-Sale is not of itemised assets-Not liable to tax-SLP of Revenue is dismissed. [S. 2(42C), 41(2), 45, 50(2), 50B(2) 55(2)(a), Art. 136]
S. 37(1): Business expenditure-Capital or revenue – Purchase of software – Not necessary that income must be earned because of such expenditure.[S. 28(i)]
S. 12AB: Procedure for fresh registration Cancellation of registration with retrospective effect-On writ filed by the petitioner, the Court granted the interim stay-SLP of Revenue is dismissed. [S. 12A, 12AA, 12AB(4), Art. 136]
S. 12AA : Procedure for registration-Trust or institution-Charitable purpose-Object and genuineness of Trust-Tribunal justified in directing the Commissioner to grant registration and also approval under section 80G(5)(vi) of the Act. [S. 11, 80G(5)(vi), 254(1)]
S. 271FAA : Penalty-Furnishing inaccurate statement of financial transaction or reportable account-Rectified the defects-Revised Form No 61B within the time allowed under section 285BA(4)-Penalty is deleted. [ S. 285BA(4), Form No 61B]